EC public consultation on risk preparedness in the area of security of electricity supply A EURELECTRIC response paper

October 2015

EURELECTRIC is the voice of the electricity industry in Europe. We speak for more than 3,500 companies in power generation, distribution, and supply.

We Stand For: Carbon-neutral electricity by 2050 We have committed to making Europe’s electricity cleaner. To deliver, we need to make use of all low-carbon technologies: more renewables, but also clean coal and gas, and nuclear. Efficient electric technologies in transport and buildings, combined with the development of smart grids and a major push in energy efficiency play a key role in reducing fossil fuel consumption and making our electricity more sustainable.

Competitive electricity for our customers We support well-functioning, distortion-free energy and carbon markets as the best way to produce electricity and reduce emissions cost-efficiently. Integrated EU-wide electricity and gas markets are also crucial to offer our customers the full benefits of liberalisation: they ensure the best use of generation resources, improve security of supply, allow full EU-wide competition, and increase customer choice.

Continent-wide electricity through a coherent European approach Europe’s energy and climate challenges can only be solved by European – or even global – policies, not incoherent national measures. Such policies should complement, not contradict each other: coherent and integrated approaches reduce costs. This will encourage effective investment to ensure a sustainable and reliable electricity supply for Europe’s businesses and consumers.

EURELECTRIC. Electricity for Europe.

Dépôt légal: D/2015/12.105/33

Markets Committee Energy Policy & Generation Committee DSO Committee

Contact: Charlotte RENAUD – [email protected] Niina HONKASALO – [email protected] Carolina VEREDA – [email protected]

EXECUTIVE SUMMARY 

EURELECTRIC welcomes the opportunity to respond to the European Commission’s public consultation on risk preparedness in the area of security of supply. We appreciate that the Commission recognises that European electricity markets are undergoing fundamental changes given the European Union’s climate and energy policy agenda. The upcoming review of the Electricity Security Directive will be a good opportunity to examine whether improvements are necessary to ensure a high-level of security of supply in the future.

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To ensure security of supply, more attention should be paid to the investment climate. It will be essential to properly value energy, flexibility and capacity so that power plants, demand response and storage are adequately remunerated, to accommodate both the short-term variations in the system and the need for system back-up that delivers longterm adequacy.

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Having the goal of energy market integration in mind and as cross-border trade develops; security of supply (SoS) should not simply be viewed in a national context but should be coordinated also at a regional and European level. A more integrated approach to risk preparedness plans in the area of SoS, including adequacy assessments is therefore needed, going beyond individual initiatives of Member States.

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High-level non-binding guidelines on risk preparedness plans would be helpful with a view to promoting comparability and assisting cooperation between Member States, but the detail of plans will inevitably vary with the physical characteristics of each national network.

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It should be noted that a number of issues related to risk preparedness are currently being dealt with in the framework of discussions on the Emergency & Restoration Network Code. It is important that any future Commission work on electricity security of supply take full account of the conclusions reached in the Code.

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DSOs will play a key role concerning the system flexibility, in a context of development of smart meters, smart grids, smart homes, self-consumption and storage. Having this in mind, DSOs should take active part in the identification of key indicators and in the assessment of risks and design of solutions to tackle them, as part of the electricity system stability plan.

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1. Whilst Directive 89/2005 imposes a general obligation on Member States to ensure a high level of security of supply, the Directive does not specify what measures Member States should take to prevent risks. Would there be an added value in requiring Member States to draw up a plan identifying relevant risks and preventive measures to respond to such risks (risk preparedness plans)? EURELECTRIC welcomes the review of the Electricity Security Directive. The European power system has undergone significant change since the Directive was agreed and it is timely to examine whether any improvements are necessary. Nevertheless, it should be emphasized that the European power system continues to provide customers with very high levels of security of supply. To ensure equally high level of security of supply in the future, more attention should be paid to the investment climate. Europe will only be able to achieve a successful decarbonisation of the economy if the electricity industry becomes investable again. It will be essential to properly value energy, flexibility and capacity so that power plants, demand response and storage are adequately remunerated, to accommodate both the short-term variations in the system and the need for system back-up that delivers long-term adequacy. Having the goal of energy market integration in mind, security of supply (SoS) should not simply be viewed in a national context but should be coordinated also at a regional and European level. As cross-border trade develops, risk preparedness in the area of SoS needs to be seen in a more integrated perspective and not only by each Member State individually. For some Member States it is also important to consider dependency on energy supply from third countries, especially with unstable political and economic situation, such as Russia, Belarus and Ukraine. EURELECTRIC agrees that every country should have obligations to elaborate preparedness plans. It is imperative that such plans are based on the specific characteristics of the domestic power system as well as the interconnections with adjacent systems. One important element is the focus on how interconnectors are operated in emergency situations. In each Member State, risk preparedness plans should include system adequacy assessments. These are necessary at national level, but regional assessments (and in time, with a more European approach to it) are becoming more important as the market becomes more integrated. Adequacy assessments should be carried out by TSOs, and where applicable, national governments in a transparent way and with a harmonized methodology across Europe based on a probabilistic approach. Such adequacy assessments would provide a broader view taking into account medium and long-term energy policy strategy along with the right investment framework to ensure system adequacy. Market participants and DSOs should actively contribute to these assessments. This could help make the assessments sounder from an economic analysis point of view so that they become more than a theoretical exercise. Furthermore, regional adequacy studies should be probabilistic, taking into account a range of climatic scenarios (in particular in the context of significant level of intermittent generation) and consider different scenarios of connection/investments/decommissioning of generation units. System adequacy assessment shall consider the possibility of early decommissioning of generating units, as a result of low profitability putting at risk the economic viability of their operation. Moreover, the involved TSO shall coordinate their system adequacy assessments to define how much they can rely on electricity imports from neighboring countries using available interconnections.

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High-level non-binding guidelines on risk preparedness plans would be helpful with a view to promoting comparability and assisting cooperation between Member States, but the detail of plans will inevitably vary with the physical characteristics of each national network. From this perspective, existing initiatives (RSCIs) on cross-border assessment of voltage and frequency stability risks (and remedial actions) should be continued. This might require the involvement of a regional entity (with the perspective to evolve towards a European entity) to have a more coordinated role, rather than sheer establishing of guidelines and monitoring. To avoid losing the focus of market integration, harmonized guidelines are very important so a later convergence can occur smoothly. In order to achieve electricity SoS for, several risks have to be addressed:   

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Grid risks: mainly N-1 of networks (in some cases N-2); Balance risks: the right amount of balancing reserves are needed; Adequacy risks: investments and disinvestment plans must be thoroughly analyzed to assess whether there is sufficient generation is available to cover demand, considering also economic conditions for generation and demand-side management; Common mode failure risks: like fuel risk (gas) has to be anticipated by sufficient diversity in the generation mix; Lack of inertia (e.g. lack of dynamic stability); Voltage stability.

Each Member State should have a risk preparedness plan setting out:   

A description of each risk; A description of actions when one of the risks occurs; A description of actions to regain the normal situations after a blackout or brown out.

It should be noted that a number of issues related to risk preparedness are currently being dealt with in the framework of discussions on the Emergency & Restoration Network Code. It is important that any future Commission work on electricity security of supply take full account of the conclusions reached in the Code. 2. If yes, what should be the minimum requirements such risk preparedness plans should comply with? For instance, should they: First of all, we consider that these questions should be ranked in the following order, to reflect their respective importance: b and c, d, e, f and a. Furthermore, the selection of actual solutions to mitigate risk should be market-based. a. Explain the various types of risks? Yes, for example the risks which we have identified before: 

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N-11 transmission grid risks are normally well followed by the TSOs.

For contingency, N-2 can also be used.

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The network codes and guidelines that are under development should ensure that system risks are to be controlled by TSOs as well. In particular, we believe that some ancillary needs are not yet sufficiently described in the draft network codes and guidelines: o o

Voltage stability (increasing risk due to less and less central production) – Need measures to mitigate risks considering cross-border cooperation Frequency stability: need to consider lack of inertia due to production from renewable energy sources like PV and wind.

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Adequacy risk is dealt with, to a certain extent, by national Governments and TSO adequacy plans. However, these plans still use a rather static approach and do not take into account the fact that the right investment framework might not be in place to remunerate the necessary existing plants to stay online or investments to ensure system adequacy. Thus, it is also important to look at the economic viability of the power plants that are assumed to be technically necessary for system adequacy (both new and existing). Indeed, some plants might be decommissioned for economic reasons and this should be properly anticipated. Such plans also lack a wider and more integrated vision of future needs in a more European (or regional in a transition stage) perspective.

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Common mode failure (fuel) risks: this is mainly for gas power plants: decisions in the gas SoS (and particularly is dependency on grid electricity) might have a direct impact on the power security of supply.

A 100% “system adequacy” is not possible in electricity systems as it would have a huge cost for society. Therefore, a certain level of reliability and quality of supply should be expressed, for example, in terms of predefined hours per annum of loss of load expectation (LOLE), level of reserve margins, expected energy not served (EENS) of a limited number of GWh, etc.. If the events are controllable, supply interruptions (as a last resort) should be organised via controlled load shedding (brownouts). Controlled load shedding should be designed in such a way that the duration is as short as possible. The concept of a European risk preparedness plan (or European aspects of risk preparedness) should be further investigated. With increasingly integrated markets, EURELECTRIC finds a need to consider risk preparedness also from a European perspective. For example, the following elements could be considered in such plans: 

Identification of roles and responsibilities;

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Key indicators on the electricity system reserve margin;

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Assessment of relevant risks and proposal of solutions to tackle them;

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Key indicators on generation capacity (current and predicted);

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Key indicators on demand and peak demand (current and predicted);

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Available tools towards the electrical system capacity and flexibility, such as availability of production flexibility, system balancing, capacity markets where needed, DSM and interconnections;

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Previous assumed investment commitments.

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These elements should be compiled by a regional entity in order to assess the risks with a regional and European wide integrated vision, taking into account energy exchanges with Third countries. The regional system operators that EURELECTRIC is arguing for in its response to the market design consultation could be in charge of compiling those elements. b. identify the demand side measures Member States plan to take (e.g., use of interruptible contracts, voluntary load shedding, increased efficiency, energy savings)? We can only agree that it is necessary to identify all possible demand side measures. It should be stressed that demand side measures should be market-based rather than centrally planned. Regulation should provide a stable level playing field in which various sources of capacity and flexibility, including generation, storage and demand response, can compete with each other. Demand side flexibility and products should be taken into account when assessing system adequacy. c. identify the supply side measures Member States plan to take (e.g., increased production flexibility, increased import flexibility)? Yes. On the supply side the following actions are possible in the scope of SoS: 

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Defining the targeted adequacy level (e.g. predefined hours per annum of LOLE ...) taking into account that reserves were defined in the past at the level of each synchronous area only at the supply side, not at the demand side. Increased flexibility of controllable power units to be incentivized via well-functioning spot markets: day ahead, intraday, balancing markets, including the cross-border component of each of these market segments ; Introducing capacity market mechanisms to ensure a certain level of adequacy through signalling the need for power plants to stay in the system or the need for new investments; Generation, storage and demand-side are possible firm capacity providers and are therefore part of the set of supply tools to ensure adequacy.

d. assess the expected impact of existing and future interconnections? Interconnectors are useful but they cannot solve all problems alone. Indeed, it is essential that generating capacity and well-functioning market products are also available on the other side of the border to ensure the right fit. The involved TSO shall coordinate their system adequacy assessments assessing how much they can rely on electricity imports from neighboring countries using available interconnections. Existing and future interconnections will allow for the provision of services which are required for future system operability. Interconnectors can provide frequency response, black start, dynamic stability, and constraint management. e. identify roles and responsibilities? Yes, it should be stressed that security of supply requires both adequacy of power networks and of generation, taking into account demand side measures, and the two elements are inextricably linked. Although TSOs have well defined roles and responsibilities, it is also important to detail how DSOs are to contribute. In a context of market integration, system operation should be framed with a broader view of all the system requirements and adequacy needs, SoS is not a responsibility of any individual generator. When the right short and long-term price signals and

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market instruments are in place, the investments that contribute to generation adequacy and system stability will be made. The same reasoning holds for investors in storage, for contributions of demand side to SoS, etc. f. identify how Member States co-operate or intend to co-operate amongst each other to identify, assess and mitigate risks? Yes. Member States should be obliged to cooperate because SoS is a common issue for all involved countries. Risks can be mitigated by:  

Progressively transferring operational responsibilities to regional System Operators in large synchronously connected zones; Implementing an appropriate market design which keeps the necessary capacity in the market and attracts the needed investments to ensure long-term system adequacy.

To avoid reduction of the interconnection capacity for domestic security reasons and to repair internal elements of a network, it is important that Member States have the possibility to help each other e.g. using emergency installations and personnel from other countries when rebuilding the power system after large outages. g. other elements? The creation of a single System Operator for a synchronous area is a long term vision. Meanwhile we are convinced that effective real-time communication and increased coordination between TSOs is extremely important. It is also important that neighbouring Member States (or from the same synchronous area) should keep each other informed about policy decisions that might affect the security of supply on synchronous area level. Cooperation of system operators of different synchronous areas and with Third Countries shall not be forgotten as well. 3. Do you think that it would be useful to establish a common template for risk preparedness plans? This might be a good idea as long as it is developed as a high-level template or as examples of best practice. It is likely to prove difficult or counter-productive to make a detailed single template to fit all circumstances. It should be necessary in some specific cases to analyse the situation on a case-by-case basis. All involved stakeholders; in particular TSOs, DSOs, generators and suppliers, customers, demand side service providers should be involved in this process. 4. Given that electricity markets are increasingly interlinked, should risk preparedness plans be prepared at the national, regional or EU level? Risk preparedness plans are highly dependent on local power system knowledge and knowhow and the characteristics of the different domestic distribution and transmission systems. Such plans should therefore be developed and prepared based on a bottom-up approach and regularly refreshed. However, a broader framework for such plans and for system adequacy would also be

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helpful particularly in the case of more closely integrated networks and this should be coordinated at regional level. The framework should also take into account cross-border connections with third countries. 5. Do you see a role for the Commission in assessing these plans? Would you see an added value of having the plans peer reviewed, at a regional or EU level? What role do you see in this context for the Electricity Coordination Group? The Commission has a role in defining the overall framework and the non-binding guidelines to monitor and address risk regarding security of supply, having in mind a more integrated European market. The Commission could also play a role in identifying gaps in national plans, but we are doubtful that detailed scrutiny of plans is necessary. This discussion should naturally be framed with stakeholders’ consultations, namely the Electricity Coordination Group. The Electricity Coordination Group has already as mission to assess the different plans, in particular ENTSO-E’s adequacy analysis. It should promote good practices, in particular crossborder cooperation. However, the analysis of the adequacy forecast depends on how the power generation capacity evolves. Therefore, the Electricity Coordination Group should also be extended with representatives of the generators (like e.g. EURELECTRIC) and customers (like e.g. IFIEC) as strongly involved parties. As an alternative, a specific European Stakeholder Committee that is sufficiently involved with the work in the Electricity Coordination Group could be established. 6. What level of transparency should be given to the plans? Who should be informed of what? As a general rule transparency is important and beneficial in promoting greater mutual confidence between Member States on cross-border supplies’ reliability. However, with increasing threats of terror attacks and cybersecurity breaches, there are often national legislation restricting the degree of transparency regarding security and preparedness plans, in particular regarding commercially-sensitive data. Nevertheless, these plans can only work if all relevant stakeholders are able to contribute and cooperate (generation, DSOs, TSOs, governments and NRAs, retail) and if a high degree of cross border cooperation is ensured. On top of that, implementation of such plans should be monitored and adjusted when necessary, which also implies the involvement of other European organizations, agencies and regulatory bodies, such as ACER, ENTSO-E, the Electricity Coordination Group and the European Commission (EC). In that perspective, all those stakeholders should be involved in the discussion of guidelines, in the preparation of the plans themselves, in the reporting of achieved results and assessments, and in the discussion of any adjustments required. 7. How often should risk preparedness plans be made / be updated? What are the relevant time frames to be covered? Risk preparedness plans must be framed in a regulatory context. Therefore, it could be reasonable to set the frame along with the regulatory period frame, establishing an annual monitoring that may result in the need for any required update/adjustment.

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The timeframes to be covered should be rather long-term, as all investments necessary to avert identified risks have long lead times by nature (new generation capacity, storage, interconnectors, transmission networks, etc.). Additionally, some new technologies will enter in the electricity world and it is impossible to predict precisely their impact and their effective contribution to the SoS (e.g. batteries as storage device, climate change, terror threats, etc.). At moments of real commercial breakthroughs of emerging technologies, the impact should be defined as soon as possible. The plans could be reviewed on a yearly basis or every 2 years, and include a projection of 5 and 10 years, similarly to the system adequacy forecasts by ENTSO-E. In addition to existing practice of ENTSO-E to produce Scenario Outlook & Adequacy Forecast (SO&AF) for a period of about 15 years (current forecast for the period 2015-2030) a longer term period until 2050 (which is the target year of EU decarbonisation policy) shall be considered once every 5 years. 8. Given the challenges that DSOs are facing (e.g. integration of renewables, more decentralised systems), should DSOs take an active participation in the assessment of the risks and preparation of the risk preparedness plans? If yes, do you see the need for separate assessments and separate risk plans at the DSO levels? Or do you believe it is more appropriate to ensure an active participation of DSOs in risk assessments and risk preparedness plans covering the entire electricity system? Yes, preparedness plans should be developed through a bottom-up approach. Given the growing amount decentralized generation at DSO level in the future, the role of DSO becomes more and more important to ensure that the electrical system remains energized. A number of issues will become important for DSOs such as frequency stability and voltage control, issues that did not exist in the past and are rather new for DSOs. DSOs will play a key role concerning the system flexibility, in a context of development of smart meters, smart grids, smart homes, self-consumption and storage. Having this in mind, DSOs should take active part in the identification of key indicators and in the assessment of risks and design of solutions to tackle them, as part of the electricity system stability plan. 9. Ensuring cybersecurity is an increasingly important aspect of security of supply. What measures should Member States take to protect themselves against possible cyber-attacks or other cyber-related threats? Do you see the need for specific EU rules on cyber security, targeted to the energy field? Given the cross-border nature of cyber security risks, what scope is there for enhancing co-operation (for instance through the exchange of best practices)? The increasing dependency of DSOs and TSOs to their technological environment clearly justifies accepting cybersecurity as a fundamental aspect for security of supply. Thus, extending the security domain to the cyber domain is clearly a key aspect for utilities today, which should envisage a common ground around this topic – given the growing European grids interconnection. Cyber-security will indeed become a major issue in the future, not the least because of the digitalisation of the power system. However, the proposal for an EU Directive on Network and Information Security (“NIS Directive”), that is currently reaching the end of the legislative process, will already provide adequate solutions to deal with these issues. We trust that it would be

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extremely valuable to have a European Energy sector cybersecurity framework and baseline that would compel all utilities to address the topic of cybersecurity. It aims to foster cooperation between Member States, increase the level of network and information security, and protect the provision of essential services in the EU. These provisions will explicitly apply to suppliers and various types of operators (including network operators) in the energy sector. Given the cross-border nature of cyber security risks, utilities should be open to join forces at a European level against cyber threats, by sharing information about threats and risks, knowledge and experience. Organization and co-operation are vital for the protection of the European power grid and lifting its resilience to a higher level. 10. Currently, it appears that in some Member States, detailed emergency plans exist, whereas in others, there are only very summary emergency plans. Should there be an obligation for all Member States to plan for crisis situations, e.g. by including relevant rules and measures in the overall risk preparedness plans? Yes, there should be an obligation to plan for crisis situations and coordinate these plans with connected systems. Preparedness plans are of vital importance in order to handle threats and incidents in the power system in an efficient way, and reduce the negative effects for society and stakeholders. Negative cross-border impacts for other connected countries/systems that are in synchronous mode or that have entered into agreements of sharing reserves and ancillary services could easily occur and should be mitigated. For example, a good practice procedure could be in Austria where they have a risk analysis project together with the national regulator and one of the core findings was to establish an Energy-CERT (computer emergency response team) centrally for the electricity and gas business. A good preparedness plan should describe:       

Methods to assess the correct quantities for FCR , FRR and RR as specified in the LFC&R code ; Level of risk in terms of achieving the adequacy standard of the system; Operational process for Voluntary load shedding based on contracts; Operational process for Voluntary limitation of consumption in given time periods (e.g. Belgian preparation for the winter 2014-2015 and the public response on it); Operational process for Cutting “nice to have” loads during a few hours with a reduced impact on the society (e.g. lighting of advertisements, design lightning of buildings, electric car charging, accumulation heating, etc.); Manual (mandatory) actions in case of emergency such as describes in the Emergency and Restoration code (System Defence Plan Art.20); Automated load shedding in case of abnormal frequency or voltage.

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11. If yes, what should be the minimum requirements to be included? For instance, should Member States be required to: a. Identify actions and measures to be taken in emergency situations (market and nonmarketbased)? It is essential to keep markets functioning as long as possible in order to ensure an efficient use of infrastructure and resources. Market suspension should therefore be limited to the most critical situations where TSOs have used all the available market-based or bilaterally contracted resources to handle the situation and have no other choice but curtail some customers. In low critical situations, market activities must be maintained. In particular, each involved party (generator/supplier/consumer/BRP) should keep its role in accordance with “normal” contracting processes. Regarding market based actions we see the items as listed in our answer to Q10. Regarding non market based items we see voltage stability and dynamic stability as the most important. b. Set out the conditions for suspension of market activities? For this question, we believe the text proposed in the draft Network Code “Emergency and Restoration” is sufficiently addressing the conditions2. As such events should not happen frequently; a more detailed description might make it too much constrained for TSOs to take decisions when such an event happens. We should however recall that the criteria for suspending market activities should include situations where market participants (BSP and/or BRP) are not able to perform their market activities and fulfil their related obligations (transparency) for reasons out of their control (power exchanges closure, lack of market liquidity, etc.). TSOs shall also provide market participants with adequate and timely information and the definition of conditions should in any case rely on fast and secured procedures that need to be jointly defined upfront in coordination with stakeholders and submitted to NRA approval.

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The rules and conditions for suspension of market activities shall cover at least the situations where prolongation of market activities would worsen the conditions of the Transmission System being in Emergency State. When defining the rules and conditions for suspension of market activities, each TSO shall consider at least the following parameters: a) a percentage of load disconnected in the LFC area of the TSO; b) a percentage of generation disconnected in the LFC area of the TSO; c) a significant part of the LFC area in desynchronised operation with the rest of the LFC area of the TSO; d) the reduction to zero of Cross Zonal Capacity on a Bidding Zone Border(s) e) a percentage of affected entities referred to in Article 33(5) not able to execute their market activities for reason(s) out of their control; and f) the absence of the proper functioning of tools and communication means necessary for TSOs to facilitate market activities.

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c. Identify categories of 'protected customers' which, in case of a crisis, should not be subject to a disconnection measure (or only be disconnected by way of a last resort)? It should be noted that the issue of protected customers in electricity is rather different from gas, given the major difficulties and costs of reconnecting small customers after a loss of gas supply. In the case of electricity, the definition of “protected customer” does not appear to be of crossborder importance, though Member States clearly should have appropriate arrangements in place. We therefore consider that the list of possible protected customers should not be limited and that Member States should have the possibility to decide the scope of protected customers considering the electricity market in their country. We are aware that some of the following categories are included in this concept:     

Hospitals and similar institutes (e.g. for disabled/elderly persons) Emergency stations (police, fire department, civil protection formations …) Telecommunication stations, energy, water, supply objects and sewerage stations, railways, airports, bus stations, meteorology centres, … SEVESO chemical sites, nuclear power plants, … …..

d. Establish rules for cost compensation? It is not trivial to set up cost compensation rules for damages caused by unplanned disconnections (and in particular black out) events. In general, supply contracts are only “agreements by means” but not by “results”. Costs for customers (and also for generators) would depend strongly on duration and frequency of the events. It is necessary however to develop specific settlement mechanisms when the suspension of market activities is required by TSOs. These specific mechanisms can no longer be driven by market-based considerations but must be oriented to ensure a “cost-efficient” dispatch, i.e. actions that will minimize global impacts on the electricity system and network users. During Emergency and Restoration States when market is suspended, TSOs are responsible to directly intervene as central dispatchers and request actions from grid users. Consequently, imbalances and the balancing energy selection and activation process are no more under the control of BRPs and BSPs, thus it does not make sense to keep a mechanism aimed at incentivizing them to be balanced. Furthermore, TSOs’ financial neutrality should be accompanied by an incentive to ensure a “costefficient” dispatch in these situations. Where no former arrangements have been set, TSOs should coordinate with grid users to define an adequate methodology for the assessment of the reasonable costs incurred by network users which take part in Defence and Restoration Plans and for the recovery of these costs. e. Indicate how they intend to co-operate with other Member States? Co-operation with other Member States will become increasingly important. Parameters in the System Defence Plan as defined in the (draft version) Emergency and Restoration Network code have to be consistent in all MS at EU level.

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The engagement of mutual assistance throughout Europe should come along with a strengthened stakeholders’ involvement in the elaboration and activation of Defence and Restoration Plans by TSOs since generation and consumption units are required to provide specific services outside market-based mechanisms. f. Reflect any other issues in their plans?  

Communication between the dispatching of a TSO and of all involved grid users is crucial regarding security (cyber-attacks) and availability in abnormal grid situations (during a blackout or brown-out). The main preparedness is through setting up relevant adequacy target levels, and where these target levels are not ensured, to improve market design in order to have sufficient adequacy in the system (e.g. via capacity markets). All resources (generation, demand, and storage) that are able to contribute to this service should be remunerated on equal footing for their service.

12. In relation to risk preparedness, how do you see the roles and responsibilities of: Security of supply is a multi-facetted issues and EURELECTRIC sees the responsibilities and roles of the various players as follows:  national governments o Develop and maintain a wise geopolitical agenda in order to facilitate access to primary fuels. Allow for all energy options and leave decisions to investors o Provide adequate economic incentives for network operators (where responsible) o Ensure efficient and timely authorisation procedures o Facilitate permitting procedures for infrastructure for primary fuels o Ensure efficient and timely authorisation procedures o Ensure appropriate emergency arrangements 

national regulators o Ensure a stable and predictable regulatory regime o Consult market actors before introducing measures o Provide adequate economic incentives for network operators (where responsible) o Facilitate and safeguard the functioning of the market o Create the market framework for system operators to purchase generation reserves and other ancillary services o Set a stable medium and long-term energy regulatory framework

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TSO's & DSO's o Ensure network adequacy and cross-border coordination o Undertake transparent network planning o Ensure non-discriminatory and transparent access to the grid o Ensure real-time balancing o Ensure safe and reliable operation of their respective systems, including the necessary international cooperation o Monitor and report system adequacy, both network and generation (but no responsibility for ensuring generation adequacy)

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European bodies such as ENTSO-E, ACER, and the Electricity Coordination Group?

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European Commission o Develop and maintain a wise geopolitical agenda in order to facilitate access to primary fuels o Keep all energy options open o Create a harmonised framework for determining the necessary cross-border interconnection capacity

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Other stakeholders, such as consumers?

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Consumers o Accept the use of various fuels and generation technologies o Accept investments in infrastructure in the neighbourhood o Participate in demand side response programmes

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Generators o Fulfil contractual obligations towards customers o Provide data for monitoring system adequacy, without revealing commercially sensitive information o Fulfil contractual obligations towards networks o Abide by corresponding market and competition rules o Adhere in all business to highest standards of probity, honesty and fair dealing o Provide ancillary services under market conditions

13. Given the fact that many actors are concerned by security of supply issues, would you see an added value in the designation by each Member State of a ‘Competent Authority’, responsible for coordinating security of electricity supply issues at national level? Most Member States are likely to have designated an authority, usually within Government, to take the lead on electricity security of supply. There would be benefits in having a clear contact point within each Member State. But the decision to set up a “Competent Authority” is up to the Member States. 14. If it is decided to strengthen regional co-operation on a more structural basis between various players (e.g., when drawing up risk preparedness plans), how should regions best be defined? Some degree of regional coordination would be beneficial. Defining regions for security of supply and preparedness plans should not deviate from regions defined for increased cooperation on system operation, transmission planning and development and market integration. Areas of synchronous operation, with high levels of physical interconnection and having common market platforms should therefore be the basis for defining such regions e.g. the Nordic region.

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